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RE: Site Visits


I find your response very interesting.  First off, I am not an "a" man.  I
am not a "b" man.  As a consultant, I try to adopt the approach that is most
effective for my client.  Every approach has its strengths and weaknesses,
and one approach is not right for every situation.

But if I had to choose, I would go with "b" more times than not.  Without a
solid knowledge of cause and effect, the blind adoption of alternatives can
lead you into trouble. Perhaps the EPA WMOA guide did not talk about cause
and effect diagrams, but it did stress the importance of mass and material
balances.  Any chemical engineer will tell you that to construct a detailed
and accurate balance, you really need to understand the process.  Once you
understand the process, the ways to eliminate waste almost become

I also agree with some of your comments regarding state and federal
programs.  Judging success by the number of alternatives offered is wrong.
You have to judge success by the number of alternatives implemented and the
amount of waste avoided. Programs should seek out ways to motivate people to
act. I know many states took the "a" approach because shops will always use
the "lack of information" excuse for not doing anything.  The truth is we
are flooded with information, what we lack is motivation. If the "b"
approach motivates people to act, then it's the better approach.

Where we do differ though is in our views of history.  I believe you are
stating there is the "a" approach, as presented in the two EPA guides, and
the "b" quality-based approach you began teaching at Tufts.  Since both
started at about the same time, there was no split.

The problem with your statement is that it shows a lack of understanding as
to what was presented in the two EPA guides.  Figure 3-1 of the WMOA guide
clearly shows that you start with the recognized need to minimize waste and
you end with successfully implemented projects. The evaluation of project
performance and the reevaluation of previous options are also part of the
overall procedure.  This sounds very much like a program rather than a
one-time assessment conducted by outsiders.

And as for the "b" approach, where does it say in these guides that this
approach cannot be used ?  I'll argue that the guides support the "b"
approach much more than they do the "a" approach.  Should the guides have
been more specific in providing tools and examples ?  Absolutely yes.  Did
people become much more wrapped up in filling out forms than in
understanding the concept and intent ?  Most likely so.

Therefore, how do we get back on track ?  Should P2 be taken away from the
environmental groups and be given to the quality groups ?  Should the
environmental groups just let the quality groups take it ?  Should
governments role in such programs be curtailed because it often leads to "a"
type thinking ?
Can a "b" approach work without upsets if there was no "a" type information
available for benchmarking ?

So many questions. Looks like I better melt my asbestos suit (treatment) and
put on some Nomex (substitution).
> ----------
> From: 	Robert B. Pojasek[SMTP:rpojasek@sprynet.com]
> Sent: 	Saturday, January 23, 1999 8:16 PM
> To: 	Callahan, Mike; p2tech@great-lakes.net
> Subject: 	Re: Site Visits
> Your "a" type of pollution prevention assessment dates back to the
> printing
> of the EPA Waste Minimization Opportunity Assessment Manual.  It was for
> environmental people to use both outside  (technical assistance providers
> and consultants) and inside the companies.  Technical assistance providers
> often get their support money from the EPA (PPIS grants) and must measure
> their performance.  This performance measurement is often accomplished by
> citing the number of visits made and the number of "right answer"
> solutions
> provided.  Little effort is spent to follow up with the firm to see if
> they
> actually implemented the right answers or continued to operate them for
> years later.   You will note that the EPA Facility Pollution Prevention
> Guide (second edition of the above mentioned EPA Guide) clearly calls for
> the assessment to be used to establish the program. 
> Your "b" type of pollution prevention goes back to about the same time
> when
> I started teaching the Systems Approach to Pollution Prevention at Tufts
> Unversity.  In this "quality-based" approach, the ASSESSMENT is only one
> (somewhat minor) component of a pollution prevention program.  Within the
> program, outside assistance (often management consultants) may help people
> within a company eliminate waste (Japanese refer to waste as MUDA).  The
> role of assistance is to FACILITATE the process of problem-solving and
> decision-making.  Waste (of any type) IS a PROBLEM to be solved using
> internal (cultural) information.  This is the type of assistance that Pat
> Gallagher of New Mexico described and it is the type of assistance that
> the
> EPA "Nothing to Waste" environmental justice program addresses.  I do not
> know of any other P2 technical assistance efforts outside of the NIST MEP
> arena that is currently using this approach.
> The EPA made a pitch for P2 Programs that had a "program element" in it
> for
> conducting periodic waste minimization assessments.  It was published in
> the FEDERAL REGISTER ( June 12, 1989 - Vol 54, No. 111, pp 25056-25057) as
> the basis for the "program in place" that every company that signs
> hazardous waste manifests is certifying that they have (yeah right!).  The
> final document was published in the FEDERAL REGISTER in 1993.  It is
> important to realize that this document specifies the program as being
> important and the assessment as only being part of the program.  This
> contrasts markedly with your "a" case.
> So you see, Mike, there was never a "split" as you called it.  You either
> did "a" or you did "b."  Both are valid and have sound bases in EPA
> publications.  I can tell you are an "a" man.  So be it.  No need to get
> stressed out over it.
> Those of us in the "b" camp, Mike, do not believe it is proper to do
> brainstorming (we prefer brainwriting) until AFTER root cause analysis is
> completed.  It is important to know why the waste exists BEFORE trying to
> eliminate the waste.  There was no coverage of root cause analysis in the
> EPA FAcility Pollution Prevention Guide.  However, the DOE Pollution
> Prevention Guide does have something that looks like a cause and effect
> diagram included in it.  We believe that there are champions for
> eliminating wastes in companies and our process finds the champions and
> place them on teams that solve problems.  Many people on P2 TECH want
> right
> answers and have even stopped brainstorming with employees.  Options (we
> call them alternatives) are coming from this listserver and are fed to the
> companies in some cases.  State P2 technical assistance providers may need
> to have this information for their performance evaluations.  This is not a
> split.  It merely follows the dictates of who is providing the money.
> Mike, you seem to suggest that the "b" approach is hard to sell or is much
> more expensive and should only follow the "a" approach.  A technical
> assistance provider offering a free service can go into a company and
> prepare a hierarchical process map and identify all the P2 opportunities
> inside a half day in most firms.  If they spent the entire day, they could
> take one of the P2 opportunities and conduct the root cause analysis,
> generate alternatives, select alternatives, and prepare an action plan.
> The employees can then use this information to work on other P2 projects.
> A program can be easily established around this information.  It is not
> more expensive.  It is only an issue in that the technical assistance
> provider will have to learn how to use the problem-solving and
> decision-making tools in the Systems Approach or other quality-based
> program.  You are right about your "old saying."  Some P2 technical
> assistance providers still love the methods they use.  However, this
> string
> started as some of these very providers are beginning to question the
> methods they have been using since 1989.  Lean manufacturing and
> just-in-time consultants are eliminating waste (includes environmental
> varieties of waste) using the "b" method.  The NIST MEP's are now charging
> for some of their services so they do not have to rely on the government
> funding that is dictating the ways of those using the "a" method.
> The notes that Pat Gallagher, Rick Grote, Dale Francke, Burt Hammner,
> myself and others have been sending to this listserver are informing those
> who use the "a" approach that the "b" approach can work well if you are
> properly trained.  Much information exists on these tools (refer to
> previous notes).  However, as Pat Gallagher will attest, you have to go
> out
> and use the tools in order to master them for working with your clients.
> I
> believe that she said that the companies that participated in her program
> had "fun."  How much fun does a company have with a checklist and a
> listing
> of "right answers" that are provided to them.  Maybe New Mexico is "on to"
> something BIG here!
> There is a rumor that the P2 providers using the "b" approach are no
> longer
> using their asbestos suits.  You might ask some of the participants in
> this
> string for some really cool subsitutes for asbestos suits.  I think there
> is a company that is melting the asbestos rendering it nonfriable.  Sounds
> like a "right answer" to me. We all want to know where you stand on the
> two
> methods, if you are in facile with problem-solving and decision-making
> approaches (remember that they youngest tool in the Systems Approach goes
> back to 1943 - long before EPA was even thought about). 
> At 01:47 PM 1/22/99 -0800, you wrote:
> >I have some questions/comments regarding site visits that may get me
> flamed,
> >but so be it.  Am I correct in my understanding that the two major
> >approaches are a) outsiders do the assessment and give the plant
> personnel a
> >shopping list of measures versus b) work with the plant personnel to
> develop
> >an understanding of the process and then have them come up with solutions
> ?
> >
> >And why is it that "a" types seem to be associated with environmental
> >programs while "b" types are associated with quality programs ?  How did
> >this split occur ?
> >
> >If there is a split, then we have a generation of people in the
> >environmental field who have been misled and mistaught as to how to
> conduct
> >a P2OA.  What ever happened to "product champion" ?  What happened to
> >brainstorming sessions and option screening by the "team" members ?  All
> of
> >these relate to the "b" approach and they did not come from quality
> >programs.  They are rooted in the common ancestors of both programs.
> >
> >As the old saying goes "What works, works."  If you offer free advice and
> >the company doesn't want you to take time away from their employees, then
> >you can only follow the "a" model.  Maybe nothing will happen, or maybe
> you
> >planted some seeds that can take root for a future "b" approach.  And if
> the
> >company spends money to take the "b" approach, then you can be assured
> >something will happen because its expected.
> >
> >Does anyone know of a substitute for asbestos suits ?
> >
> >Mike.callahan@jacobs.com
> > 
> Bob
> Dr. Robert B. Pojasek 
> Pojasek & Associates 
> P.O. Box 1333 
> E. Arlington, MA 02474-0071
> (781) 641-2422 
> (617) 788-0288 (FAX)
> http://www.PollutionPrevention.com
> rpojasek@PollutionPrevention.com